From Enforcement to Compliance through Best Practices and Provider Support Services Presented by Sandra Wooters and Debra Avery, PA Dept. of Public Welfare, Adult Residential Licensing

Provider Support Services is: Services designed to encourage voluntary care improvement; Services that protect the public by helping providers to increase their knowledge, thus improving services and rules compliance; A strategy for improving consumer protection while reducing the proportional effort that might otherwise be directed at enforcement.

Provider Support Services is: (Cont.) The “hidden backbone” of consumer protection.

Provider Support Services: From Enforcement to Rule Compliance

Special Challenges Faced by Facilities Caring for Low Income Consumers Experienced licensor’s are sensitive to the different compliance issues for small facilities, rural facilities, low income facilities, chain operated facilities, etc.; In these times of economic uncertainty Providers are being asked to do more with less money, and with less support from community social services agencies.

(Former Honeywell CEO Larry Bossidy Goal: Affordability “No worthwhile strategy can be planned without taking into account the organization's ability to execute it…” (Former Honeywell CEO Larry Bossidy and business consultant and author Ram Charan in their book titled Execution: The Discipline of Getting Things Done)

Goal: Affordability (Cont.) It is wrong to assume that maximum quality is the ultimate goal. Should every hotel be built to the same quality as The Ritz? Simplify, and where appropriate, reduce the number of procedures and process that reflect how work actually gets done. Help identify strategies unique to the environment and population served. Approach compliance in a positive and supportive manner.

Goal: Affordability (Cont.) Some of the best tools include: A three ring binder A highlighter A hole punch A rubber finger

Goal: Advice, not rule enforcement! All advice, however formal or informal it may be, must always leave the other person completely free to accept or reject it! Suggest options generally available, or available in that provider’s particular situation, which would achieve compliance with the rule. Inquire what are the needs of the provider…many times their actual needs are not based on a regulation but end up affecting regulation compliance.

Goal: Accountability/Responsibility Place and keep responsibility for compliance on the provider; The licensor should encourage but not become over-invested in the provider’s success; The goal is to build self-reliance and managerial competence among providers; Tie updated processes to individual job responsibilities.

Goal: Accountability/Responsibility (Cont.) Accountability is external. It is an agreement to be held accountable by another for your operation or results. Responsibility is internal. It’s a feeling of ownership. True responsibility stands out because people are leading, learning, correcting, and improving. The sign of a healthy, high-performing facility.

Goal: Use a “Systems Approach” to Problem Solving View “problems” as parts of an overall system and solution, rather than react to a specific part, outcome or event; Consider all possible interactions involved with the problem situation; Consider three types of changes; changes in structure, in procedures, and in attitudes.

Goal: Use a “Systems Approach” (Cont.) What Happened? Why did it happen? What can be done to prevent it from happening again? How often is the system going to be monitored and by whom?

Goal: Provider Self-Sufficiency Build a network of provider support. Achieved thru use of self, agencies and the community at large.

Goal: Provider Self-Sufficiency (Cont.) What are the strengths of the provider and staff? What agencies and community organizations have resources to offer to the facilities? Encourage the provider to reach out to other providers who have been successful following the rule. Help the Provider develop a monthly provider network meeting.

Tools Tools must be affordable and easily achievable by both staff and administration. Tools should be designed in a proactive approach to rules and not reactive. Tools should include auditing, review, observation and training. Tools should be used daily, weekly or monthly in an effort to reduce repeated non-compliance. Develop a team approach to compliance. Help the staff understand the rules which will empower the staff to join the process.

Best Practices Some of the best tools include a 3 ring binder, a highlighter, hole punch and a rubber finger! Create a good policy and procedure manual that can also be used to train staff. Encourage the development of a licensing ready book. Review a non-compliance report and assist in the development of an auditing, review or observation tool. Be sure the steps are easy to understand, who is responsible and how often will the non-compliant area be monitored, audited or observed.

Best Practices (Cont.) Utilize a “Walk About Workshop” to instill a new system designed by the staff. Walk About Workshops, or instant in-services, are key to helping staff gain a greater knowledge of a rule and how to fix the rule once observed. The Walk About Workshops are 15 minutes or less of training that can be completed at each staff’s work station, in the office, or in the break room. Review the process with all of the staff involved in that process. Don’t’ forget to get staff signatures!

Best Practices (Cont.) Staff must understand what happened and why it was non-compliant. Work with the staff on how to achieve compliance. They usually know why an event happened, and can help develop a good “system” to prevent it from happening again. Ongoing staff training on regulations is one of the best methods to achieve compliance.

Best Practices (Cont.) An example of a simple observation tool to reduce physical site non-compliance is a one page foldable tool that fits into the staff’s pocket and reminds the staff of what to observe to reach rule compliance. The physical site is ready for inspection at anytime!

Best Practices (Cont.) An example of typical non-compliance is medication documentation errors. Med errors can be easily identified by staff, if trained on what to look at on the Medication Administration Records. Ask the medication staff “how do you end or begin your shift”…..the answer should be “check the medication administration record for missed documentation at the beginning and end of each shift”…..encourage the staff towards this approach…..this is an easy, no cost fix…alas….……a reduction in documentation errors!

A Strong Provider Support Component is one that: Increases compliance and consistency in regulatory compliance Improves relationships between licensees and licensors Reduces the need for sanctions Reduces time licensors spend on inspections and complaints Increases support for sound regulation Increases support for consumers

Conclusion Provider Support Services do more than give providers tools and technical support. They also model a value and goal that should be the heart, soul and the driving force of every human service care facility or agency. Provider Support Services is the link between licensing and provider compliance.

Resources Commonwealth of Pennsylvania Provider Support Program tools Commonwealth of PA’s 2011/2012 inspection results